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Legal Alerts and News Updates

White House OSTP Releases Streamlined Research Disclosure Standards

On Aug 31, 2022, the White House published An Update on Research Security: Streamlining Disclosure Standards to Enhance Clarity, Transparency and Equity in the Office of Science and Technology Policy’s (OSTP) blog. This communication provides a brief update on the federal government’s ongoing efforts to enhance research security of the U.S. research enterprise through the implementation of measures outlined in National Security Presidential Memo (NSPM)-33.

Specifically, the OSTP update provides information on efforts to streamline and harmonize the disclosure process, including the forms used across federal science funding agencies for the reporting of potential conflicts of interest and conflicts of commitment for federal grants and cooperative agreements.

As part of this effort, following many months of interactions with the research community, the National Science and Technology Council’s Subcommittee on Research Security has identified a set of standardized data fields for research disclosures and developed draft templates with instructions for the generation and submission of a common Biographical Sketch and a common Current and Pending (Other) Support information for senior/key personnel. Included with the templates is a link to an updated version of the NSPM-33 Implementation Guidance for Pre- and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support. This table provides helpful information and increased clarity relating to how and when various types of activities need to be disclosed and/or updated with regard to federal research funding agencies. According to the blog post, all of the federal science funding agencies have agreed to moving forward with adopting standardized disclosure formats, though each agency will still have the ability to develop agency-specific data elements, forms and instructions as needed. Any agency-specific requirements, however, will require approval by Office of Management and Budget, Office of Information and Regulatory Affairs, under the Paperwork Reduction Act.

In order to gather public comments on the new forms and data elements, the National Science Foundation (NSF) published a notice of agency information collection activities on August 31, 2022: National Science Foundation, Agency Information Collection Activities: Request for Comment Regarding Common Disclosure Forms for the Biographical Sketch and Current and Pending (Other) Support. The federal notice explicitly requests feedback on the scope and utility of the information collected, the accuracy of the estimate of the burden, suggestions on how to enhance the quality, utility and clarity of the information being collected, including the use of automated collection, and any ways to reduce the burden on respondents. Comments are due no later than October 31, 2022.

On its face, this effort to standardize disclosures across research funding agencies could significantly ease research compliance burdens for institutions of higher education — but only if the agencies refrain from overloading the forms with agency-specific data elements.



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